Wednesday, July 8, 2020

Eastern District Court of Pennsylvania Addresses Issues of Personal Jurisdiction



In the case of Crockett v. Luitpold Pharmaceuticals, Inc., No. 19-276 (E.D. Pa. June 11, 2020 Beetlestone, J.), the court granted a Motion to Dismiss on personal jurisdiction grounds. 

That a Defendant who designed a product that harmed an individual in Pennsylvania, in and of itself, is insufficient to establish jurisdiction

The court also ruled that a steam of commerce is not a viable jurisdictional theory. 

The court in this Crockett case more specifically indicated that a party who does not do any business in Pennsylvania does not subject itself to jurisdiction by cooperating with a third party that is engaged in business in Pennsylvania. A relationship with such a third party is not sufficient to establish jurisdiction under Pennsylvania law. 

The court emphasized that the Defendant at issue in this case had no contacts of its own in Pennsylvania. 

As such, that Defendant’s Motion to Dismiss was granted. 

Anyone wishing to review a copy of this decision may click this LINK.  The related Court Order can be viewed HERE

I thanks to Attorney James M. Beck of the Philadelphia office of the Reed Smith law firm for bringing this case to my attention.

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